In the past, we have been able to depend on
the California air regulators for taking science based, data driven
approaches to solve problems. This ATCM proposal is evidence that
science and data are trumped by politics.
According to the SCAQMD MATES V study,
there are over 300 pounds of hex chrome emitted annually in the
region. Note, that is only in the South Coast area, not the entire
state. Let’s call it 500 pounds in the state.
According to the CARB ISOR, SRIA, and
Appendix B of this ATCM, the amount of PERMITTED Hex Chromium
emissions by chrome platers in THE ENTIRE STATE is 10.19
pounds.
According to the CARB Appendix B of this
ATCM, the ACTUAL Hex Chromium Emissions by chrome platers in the
ENTIRE STATE are 0.901 pounds.
So, this proposed rule bans decorative
platers in the short term, and functional platers in the long term
to save less than 0.2% of the hexavalent chromium emissions in the
state. That is one pound out of 500.
CARB presents the purpose for the rule
change as being necessary to achieve environmental justice goals.
(See the purpose section of the ISOR pages 1 to 5). But, based on data, this
doesn’t even seem to be valid. You can see for yourself if
you take the time to read the AB 617 process Community Emissions
Reduction Plans from the following environmental justice
communities: 1) Wilmington, Carson, and West Long Beach; 2) San
Bernardino / Muscoy; 3) East LA, Boyle Heights; 4) East Coachella;
5) South LA; and 6) Southeast LA. All of those community generated plans (with one
exception) appropriately recognize that chrome plating firms are
not an area of concern. So, who is CARB listening to?
Why would CARB move to implement a
STATEWIDE ban based on what might be an issue in one EJ community?
Keeping in mind that metal working is a major job engine for
California, is this how social justice is supposed to work. Do jobs
count for anything?
It seems to me that the whole point of the
EJ movement is to be responsive to people in their communities. So,
to do that, the state (CARB) should not implement statewide edicts
that impact communities other than the ones where problems may
exist. Otherwise, they create more problems than they solve! Things
just get worse in more communities.
It is a fact that stainless steel contains
chromium. According to CARB and AQMD and science, the heating,
forging, grinding, milling, melting, welding, and cutting of
stainless steel releases hexavalent chromium. It isn’t just
chrome plating. So, is this rule-making a shot across the bow to
the entire metal working industry in California? Should we all just
leave now? After all, the metal finishers were told repeatedly that
since there is no “safe” level for hexavalent chromium
it was necessary for CARB staff to propose this complete ban based
on California health and safety laws. They say they have no choice.
If that is the case, then machinists, welders, recyclers,
fabricators, heat-treaters and all other metal workers will soon
join the chrome platers in the unemployment line.
According to the American Cancer Society,
hexavalent chrome causes cancer. Somehow, the California Health and
Safety Code and therefore CARB bans it.
But, also according to the American Cancer
Society, alcoholic beverages (wine) cause cancer. California
markets it to the world and our governor owns a wine business. I
call bullstuff on the lie that CARB is forced to impose a
ban.
There are serious problems at CARB. They
are being pulled away from data and science. It is hurting the
state. High-paying, middle-class jobs are leaving. As CARB focuses
on satisfying squeaky wheels it loses credibility on this and other
important work. The job of a regulator is to adopt thoughtful
rules, a ban is not thoughtful. CARB should adopt an emissions
based approach.